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Abstract
Deepfake governance — disclosure, watermarking, and election-integrity protections for AI-generated media — is among the more widely addressed topics in the catalogue. Several instruments impose a direct disclosure or labelling duty, led by the EU AI Act's Article 50(4) transparency obligation and China's labelling rules, alongside a cluster of voluntary codes; others reach it only implicitly or are silent. Policy Window records the empirical consensus as contested: jurisdictions have largely converged on requiring disclosure, yet the field is split on whether watermarking survives adversarial removal at scale. This article maps each instrument's treatment with primary-source citations.
Definition & scope
The cross-jurisdiction picture below shows how each of 45 tracked instruments treats this topic. The patterns vary substantially — and 31 regimes are silent, leaving gaps that future policy work could address.
Coverage across jurisdictions
Historical primacy & cross-jurisdiction tension
First addressed by Provisions on the Administration of Deep Synthesis of Internet Information Services on (governs). Subsequent regimes have either codified, diverged from, or remained silent on this baseline.
- Forum-shoppingEU AI Act↔Executive Order 14179 — Removing Barriers to American Leadership in AI
- Forum-shoppingExecutive Order 14110 on Safe, Secure, Trustworthy AI↔UK Pro-Innovation Approach to AI Regulation (White Paper)
- Forum-shoppingInterim Measures for Generative AI Service Management↔OECD AI Principles (Recommendation)
Compare jurisdictions: EU vs US · EU vs UK · EU vs CN
Enforcement & impact
Silent regimes — gap signal
Instruments that do not address Deepfakes / Synthetic Content — candidates for future policy work.
- Executive Order 14179 — Removing Barriers to American Leadership in AIUS
- UK Pro-Innovation Approach to AI Regulation (White Paper)UK
- OECD AI Principles (Recommendation)OECD
- Council of Europe Framework Convention on AIcouncil_of_europe
- Bletchley Declaration on AI Safetyglobal
- Seoul Declaration on Safe, Innovative and Inclusive AIglobal
- California SB-1047: Safe and Secure Innovation for Frontier AI Models ActUS
- Brazil AI Bill (PL 2338/2023)BR
- ASEAN Guide on AI Governance and EthicsASEAN
- African Union Continental AI StrategyAfrican_Union
- Anthropic Responsible Scaling Policy (RSP) v2US
- OpenAI Preparedness FrameworkUS
- Google DeepMind Frontier Safety FrameworkUS
- Meta Frontier AI FrameworkUS
- UK-US AI Safety Institute Memorandum of Understandingglobal
- Japan METI AI Guidelines for BusinessJP
- General Data Protection Regulation (GDPR)EU
- EU General-Purpose AI Code of PracticeEU
- OMB Memorandum M-24-10 (Advancing Governance, Innovation, and Risk Management for Agency Use of AI)US
- GSA Generative AI and Specialized Computing Infrastructure Acquisition Resource GuideUS
- DoD Responsible AI Strategy and Implementation PathwayUS
- FedRAMP AI Cloud Procurement GuidanceUS
- DFARS Subpart 252.204 (Safeguarding Covered Defense Information and Cyber Incident Reporting)US
- California SB-53: Transparency in Frontier Artificial Intelligence Act (TFAIA)US
- California SB 243: Companion ChatbotsUS
- Revised Product Liability Directive (Directive (EU) 2024/2853)EU
- UNESCO Recommendation on the Ethics of Artificial IntelligenceUNESCO
- Directive (EU) 2024/2831 on improving working conditions in platform workEU
- New York RAISE Act: Responsible AI Safety and Education ActUS
- Japan AI Promotion Act (Act on the Promotion of Research, Development and Utilization of AI-Related Technologies)JP
- UN Global Digital CompactUN
See also
Further reading
16 academic & grey-literature sources bearing on this topic — catalogued metadata with a primary link; one-line findings are ✦ AI-generated summaries, labeled as such (charter §7.9). Browse the full literature index.
- The Current Landscape of Deepfake Legislation in the United States Peer-reviewed✦ AIThematic analysis of 319 state deepfake bills (2019-2024) finds a fragmented patchwork concentrated on political and sexually-explicit content.
- Reimagining U.S. Tort Law for Deepfake Harms: Comparative Insights from China and Singapore Peer-reviewed✦ AIArgues fragmented US tort doctrines (defamation, publicity, IIED) are ill-suited to deepfake harms and draws remedial lessons from Chinese and Singaporean law.
- A Teleological Interpretation of the Definition of DeepFakes in the EU Artificial Intelligence Act—A Purpose-Based Approach to Potential Problems With the Word 'Existing' Peer-reviewed✦ AIWarns a narrow reading of 'existing' in the AI Act's deepfake definition could exclude synthetic media from transparency duties, urging a teleological interpretation.
- Audio deepfakes and the regulation of the landlords of creativity Peer-reviewed✦ AIArgues US, EU and Chinese regimes fail to assign audio-deepfake liability to 'landlords of creativity' (foundation-model providers) and proposes holding them accountable.
- Human detection of political speech deepfakes across transcripts, audio, and video Peer-reviewed✦ AIExperiments show "audio and visual information enables more accurate discernment than text alone" — humans rely more on how something is said than on transcript content.
- When non-consensual intimate deepfakes go viral: The insufficiency of the UK Online Safety Act Peer-reviewed✦ AIArgues the UK Online Safety Act 2023 inadequately addresses non-consensual intimate deepfakes as image-based sexual abuse, leaving enforcement and takedown gaps.
- AI or Your Lying Eyes: Some Shortcomings of Artificially Intelligent Deepfake Detectors Peer-reviewed✦ AIArgues detector-based solutions depend on scarce institutional trust and risk undermining epistemic autonomy, so purely technological fixes for deepfakes are dim.
- The Liar's Dividend: Can Politicians Claim Misinformation to Evade Accountability? Peer-reviewed✦ AIFive survey experiments (>15,000 US adults) show false 'it's a deepfake/fake news' claims can help politicians retain support, evidencing the liar's dividend.
- Deep fakes and the Artificial Intelligence Act—An important signal or a missed opportunity? Peer-reviewed✦ AICritiques the EU AI Act's placement of deepfakes in the 'limited risk' tier, leaving transparency obligations as the only direct safeguard without bans or victim remedies.
- Non-Consensual Synthetic Intimate Imagery: Prevalence, Attitudes, and Knowledge in 10 Countries Peer-reviewed✦ AISurvey of >16,000 respondents across 10 countries finds NSII victimization/perpetration persists even where specific laws exist, suggesting current laws under-deter.
- Deepfakes and the epistemic apocalypse Peer-reviewed✦ AIArgues deepfake threat to recordings is overstated once social norms are recognised and that policy has been overly focused on technological interventions.
- The Epistemic Threat of Deepfakes Peer-reviewed✦ AIArgues deepfakes pose an epistemic threat because they "reduce the amount of information that videos carry to viewers", undermining knowledge acquired from video evidence.
- Deepfakes and Disinformation: Exploring the Impact of Synthetic Political Video on Deception, Uncertainty, and Trust in News Peer-reviewed✦ AIExperiment finds people "are more likely to feel uncertain than to be misled by deepfakes, but this resulting uncertainty, in turn, reduces trust in news on social media".
- Deep Fakes: A Looming Challenge for Privacy, Democracy, and National Security Peer-reviewed✦ AIMaps deepfake harms across privacy, democracy, and national security and evaluates civil, criminal, and regulatory responses as fakes grow "increasingly resistant to detection".
- OECD AI Incidents Monitor, an evidence base for trustworthy AI - OECD.AI Incident database✦ AIOECD tracker of real-world AI incidents and hazards.
- One Hundred Year Study on Artificial Intelligence (AI100) Research institute✦ AIStanford's standing century-long study of AI's societal impact.
References
The primary instrument sources behind the article's classifications.
- EU-AIA-2024: Art. 50(4) (disclosure obligation for deep fakes)
- US-EO-14110: §4.5 (content authentication, watermarking) — rescinded 20 Jan 2025 by EO 14148; successor EO 14179 is silent on deepfakes, leaving only NIST provenance artifacts
- CN-GENAI-2023: Art. 12 (labelling) + Deep Synthesis Rules
- G7-HIROSHIMA: Code §5 (content provenance + watermarking)
- UN-RES-2024: References disinformation broadly
- NIST-AI-RMF: GenAI Profile addresses synthetic content
- NIST-AI-RMF-GENAI: NIST AI 600-1 §3.11 Confabulation + §3.10 Information Integrity (synthetic content)
- IN-DPDP-2023: MEITY Mar-2024 Advisory + IT Rules 2021 §3(1)(b)(v) deepfake takedown obligations
- WH-VOLUNTARY-2023: Commitments §5 (watermarking + content provenance for AI-generated content)
- SG-MODEL-AI-2024: Framework Dimension 7 — content provenance + synthetic-content disclosure
- CA-SB-942: 'Deepfake' appears only in the SB 942 Legislative Counsel's Digest (a recital about a separate law), never in operative §§ 22757.1–22757.4; a deepfake produced by a covered provider's GenAI system is nonetheless a subset of the AI-generated image/video/audio reached by the § 22757.3(b) latent-disclosure and § 22757.2 detection duties
- CN-DEEPSYN-2022: Art. 17
- US-TAKEITDOWN-2025: Pub. L. 119-12 — criminalizes nonconsensual intimate 'digital forgeries' (AI deepfakes) of adults and minors and requires covered platforms to remove them within 48 hours; the statute names 'artificial intelligence' in its operative digital-forgery definition
- IT-AILAW-2025: Art. 26(1)(c) inserts new Criminal Code Art. 612-quater: illicit dissemination of AI-generated or altered images/video/voices, without consent, apt to deceive and causing unjust harm — 1 to 5 years' imprisonment (querela-based; ex officio in aggravated cases).
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14 instruments tracked.